ML18010A499

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Forwards Response to NRC 911209 Request for Addl Info Re Transamerica Delaval,Inc Diesel Generator Insp Requirements.Insp Requirements Expected to Be Completed During Next Refueling Outage,Scheduled for Sept 1992
ML18010A499
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 01/13/1992
From: Vaughn G
CAROLINA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-92-002, NLS-92-2, NUDOCS 9201210121
Download: ML18010A499 (18)


Text

ACCELERATED DI TRIBUTION DEMONS TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9201210121 DOC.DATE: 92/Ol/13 NOTARIZED:

NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION VAUGHN,G.E.

Carolina Power 6 Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC 911209 re'quest for addi info re Transamerica Delaval,Inc diesel generator insp requirements.Insp requirements expected to be completed during next r'efueling outage, scheduled for Sept 1992.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED:LTR g ENCL Q SIZE:

TITLE: OR Submittal:

General Distribution NOTES:Application for permit ren'ewal filed.

DOCKET g

05000400 D

/

05000400 A RECIPIENT ID CODE/NAME PD2-1 LA MOZAFARI,B.

INTERNAL: ACRS NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB8H7 NUDOCS-ABSTRACT OGC/HDS1 RES/DSIR/EIB EXTERNAL: NRC PDR COPIES LTTR ENCL 1

1 2

2 6

6 1

1 1

1 1

1 1

1 1

0 1

1 RECIPIENT ID CODE/NAME PD2-1 PD NRR/DET/ECMB 7D NRR/DOEA/OTSB11 NRR/DST/SELB 7E NRR/DST/SRXB 8E OC 01 NSIC COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAFfE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 24 ENCL 22 D

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Carolina Power 8 Light Company P.O. 8ox 1551 ~ Raleigh, N.C. 27602 G. E. VAUGHN Vice President Nuclear Sewices Department iQAN13 1992 SERIAL:

NLS-92-002 United States Nuclear Regulatory Commission ATTENTION:

Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50;400/LICENSE NO. NPF-63

RESPONSE

TO NRC REQUEST FOR ADDITIONALINFORMATION REGARDING TRANSAMERICA DELAVAL, INC. DIESEL GENERATOR INSPECTION REQUIREMENTS Gentlemen:

The purpose of this letter is to provide Carolina Power

& Light Company's (CP&L) response to your Request for Additional Information, dated December 9,

1991, pertaining to diesel generator inspection requirements at the Shearon Harris Nuclear Power Plant (SHNPP).

On September 16,

1991, CP&L notified the NRC that certain measurements were omitted during a required five-year inspection of a diesel generator at SHNPP.

Subsequently, on September 25,

1991, CP&L submitted information concerning plans to complete the inspection requirements during the next refueling
outage, currently scheduled for September 1992.

The enclosure to this letter contains CP&L's responses to each of the items identified in your December 9,

1991 letter.

Please refer any questions regarding t:his submittal to Mr. L. S. Rowell at (919) 546-2770.

G.

E. Vaughn LSR/jbw (1457HNP)

Enclosure cc:

Mr. S.

D. Ebneter Ms. B. L. Mozafari Mr. J.

E. Tedrow r

9201210121 920113 POR ADOCK 05000400 a

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ENCLOSURE Page 1

SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63

RESPONSE

TO NRC REQUEST FOR ADDITIONALINFORMATION DIESEL GENERATOR INSPECTION REQUIREMENTS 1.

Discuss the basis for establishing the diesel generator operability date of October 24, 1986.

CP&L Res onse:

The emergency diesel generator (EDG) operability date coincides with the date that SHNPP received a Low-Power License from the NRC, October 24, 1986.

2.

When was start-up testing completed for each diesel?

a)

What were the totals for hours of operating time and effective full-load hours during start-up testing for each?

b)

. After start-.up testing was completed, were the diesels used before the operability date of October 24, 1986?

Discuss the purpose, the total operating time, and the total full-effective hours associated with each engine.

c)

Provide the total number of hours that each diesel has accumulated since low-power operation began in October 1986.

(Effective full-load and total'perating time).

CP&L Res onse:

Start-up testing was completed on June 24, 1986 for EDG "A" and on July 11, 1986 for EDG "B."

a)

Operating time and effective full-load hours during start-up testing are summarized as follows:

EDG "A" r

First EDG Start on July 25, 1985 with 42.2 factory test hours on the engine Functional Testing and Extended Run conducted from July 25, 1985 through August 29, 1985 Engine hours accumulated 210.3 Total accumulated engine hours 252.5 Effective Full-Load Hours (this period) 154.25 (145?HHP)

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ENCLOSURE Page 2

Functional Testing and Pre-Operational Testing conducted from March 7, 1986 through June 24, 1986 Engine hours accumulated - 95.3 Total accumulated engine hours - 347,.8 Effective Full-Load Hours (this period) - 35.0 EDG IIB II First EDG Start on November'15, 1985 with 11.0 factory hours on the engine Functional Testing and Pre-Operational Testing conducted from November 15, 1985 through July 11, 1986 Engine, hour accumulated - 149.0 Total accumulated engine hours 160.0 Effective Full-Load Hours (this period) - 58 '

b)

Following Pre-Operational/Start-up

testing, the EDGs were operated monthly to satisfy plant surveillance test procedures.

Additionally, both EDGs were operated for the performance of Emergency AC Power Systems Testing which included Blackout

Testing, Sequencer
Testing, and the performance of several Operations Surveillance Tests (OSTs).

The following describes the use of the diesel engines from the completion of start-up testing through Fuel Load of SHNPP on November 17, 1986:

EDG "A" Engine hours accumulated - 66.7 Total accumulated engine hours 414.5 Effective Full-Load Hours (since last block top inspection) 81.0 EDG "B" Engine hours accumulated - 60.9 Total accumulated engine hours - 220.9 Effective Full-Load Hours (this period) 102.2 c)

The total number of hours that each diesel engine has accumulated since lower-power operation (November 17, 1986 through November 30, 1991) is summarized as follows:

EDG "A" Engine hours accumulated - 370.2 Total accumulated engine hours - 784.7 Effective Full-Load Hours (this period) - 265.0 Effective Full-Load Hours (since last inspection) 346.0 Estimated Effective Full-Load Hours (at end of current operating cycle) - 405 (1457HNP)

ENCLOSURE Page 3

Engine hours accumulated 361.2 Total accumulated engine hours 582 '

Effective Full-Load Hours (this period) - 250 '

Effective Full-Load Hours (since last block inspection)-

352.7 Estimated Effective Full-Load Hours (at end of current operating cycle) - 412.0 Provide the basis for your determination that the components not inspected as required by the Transamerica Delaval, Inc. (TDI), Owners Group, during the five-year inspection, were "visually inspected with satisfactory results,"

as noted in your letter dated September 25, 1991.

CP&L Res onse:

Plant procedure MPT-M0007 (EDG Connecting Rod Inspection) requires the maintenance technicians to visually examine the piston skirt bushings for any abnormal conditions prior to reassembly of the piston to the connecting rods.

Procedure MPT-M0008 (EDG Piston Inspection) requires the technicians to perform an inspection of the link rod box surface for any abnormal conditions per the Owners Group matrix criteria recommendations.

Abnormal conditions include such things as spalling, visible metal wear, cracks, etc.

There were no abnormal conditions identified during the inspection.

Therefore, CP&L determined that the results were satisfactory.

What is the justification for continued operation when the licensing basis was not met due to omission of required recorded measurements of several components for the "A" diesel engine, as recommended by the TDI Owners Group in their Design Review/Quality Revalidation report, dated May-1, 1986?

Was a review completed in accordance with 10CFR50.59?

CP&L Res onse:

NUREG-1216, "Safety Evaluation Report Related to the Operability and Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc.," Sections 2.1.3.1 and 2.1.3.6.1 specify that major engine component and connecting rod inspections will be performed on a one-time basis following five years of service or after about five years of

service, respectively.

Since the first outage following the five-year anniversary date from the Low-Power Operating License (October 24, 1986) will be Refueling Outage No. 4, currently scheduled for September

1992, there was no omission of required measurements or a failure to meet the licensing basis of the facility.

Therefore, in accordance with NUREG-1216 and NUREG-1038, "Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear Power Plant, Unit No.

1, Supplement No. 4,"

the basis is established for the performance of inspections of both EDGs no later than the outage following the five-year anniversary date.

Accordingly, a 10CFR50.59 review was not required.

<1457HNP)

ENCLOSURE Page 4

Provide the basis for completing both "A" and "B" diesel generator inspections at the end-of-cycle (EOC) after five years versus

doing, as recommended by the TDI Owners
Group, one engine at the closest EOC prior to five years and the other at the EOC after five years.

CP&L Res onse:

CP&L is following the Owners Group recommendations to complete the inspection of one engine at the closest EOC prior to five years and the other at the EOC after five years.

Engine operating hours accumulated between refueling outages is approximately 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />, or about 90 Effective Full-Load Hours.

The one-time five-year inspection is intended to assess if engine conditions will support a ten-year overhaul inspection interval instead of the original five-year overhaul inspection interval.

NUREG-1216, Section 2.1.3.1 states that the inspection of major engine components will be performed on a one-time basis following five years of service.

Section 2.1.3.6.1 of NUREG-1216 also discusses inspections after five years.

CP&L's intent, as was the Owners'roup, was to minimize extended outages of safety-related equipment by performing one five-year inspection prior to the five-year anniversary date.

However, had CP&L elected to perform both engine five-year inspections during the upcoming Refueling Outage No

~ 4, the first outage following five years of service, no discernable differences in component wear should be apparent provided that proper maintenance of engine lube oil characteristics is performed and that'he engine is operated in accordance with vendor recommendations.

CP&L has contacted other utilities who have obtained the component dimensions in question and determined that no discernable wear has been measured at those plants.

Discussions with the vendor indicate that the link and bushing wear life is approximately 11,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> or more and that the piston skirt bushing wear life is greater than 11,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

Therefore, based upon (1) engine lube oil condition, (2) an analytical sample of other utilities, and (3) no discernable or abnormal wear characteristics on other engine components inspected, completion of the component measurements in question during Refueling Outage No.

4 is acceptable without any reduction in the engine reliability.

Discuss what actions have been completed, or are scheduled to be completed, to ensure all recommended inspection points and measurements are reviewed and incorporated into Carolina Power

& Light Company's Maintenance Inspection and Procedure Records'P&L Res onse:

Procedures MPT-M0007 and MPT-M0008 are being revised to incorporate changes which will ensure that recommended inspection points and measurements are reviewed and incorporated into CP&L's Maintenance Inspection and Procedure Records.

The revised procedures will be approved prior to the start of Refueling Outage No. 4, currently scheduled to begin in September 1992.

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ENCLOSURE Page 5

7.

Submit for review the results of the oil analysis completed during the "A" diesel generator inspection and indicate if any metal particulate was present.

CP&L Res onse:

Lube Oil Sample No. 45 was obtained during "A" diesel generator operation prior to the performance of the five-year inspections in order to obtain Maximum Firing Pressures.

Sample No. 46 was obtained during the performance of "A" diesel generator operability testing following the Refueling Outage No.

3 inspections.

The results of both of these samples are attached.

As shown in the attached, the results indicate normal operation and provide data on metal particulate concentration.

The results of Lube Oil Sample Nos.

35 and 52 are also attached to show the lube oil historical trend for the period May 8,< 1989 through October 7,

1991.

(1457HHP)

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EQUIPMENT..CONDITION REPORT.

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NEW HILL,NC SHEARON HARRIS NUCLEAR POWER NORMAL SAMPLE ID: SHNPP-A-EDG SAMPLE DESC:

A EMERGENCY DIESEL GENERATOR LUBRICANT: MOBILGUARD 412 RESERVOIR CAP:

1,500.00 GAL TIMEON LUBE:.0 HOURS MACHINETIME:.0 HOURS Recommendatlon:

Continue normal operation and sampling.

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SAMPLE DATE: 05/07/90 REC'D DATE: 06/07/90 REPORT DATE: 06/08/90 CALLDATE:

1ST SAMPLE: 12/20/86 SAMPLE 8:

35 PREY SAMPLE: 04/11/90 Discussion of, Results:

The wear particle concentration has increased from 23.9 to 25.6 in this unit. However, few wear particles are present in this sample that would indicate a problem in a unit of this type. Sample at regular intervals.

24 15 Wear Particle Concentration:

Moan wpc:

25.6 DL 16.0 DS:

9.6 VISCOSITY

13.6 WATER NEG MEAN:

14.064 STD DEV:

5.431 24 15 12 Viscosity IEI 14.Best 100c)'.

e 201C Spec.

~10%

0 24 145 05/0$ /50 Analytical Results:

222 205 570 05/15/00 0

24 05/05/40 145 222 205 020 05/15/00 WEAR PARfCLES Normal Rubblny Saeara Skdlny Curdny Bav Bavlny Splearaa Black Orddaa Rad Oeddaa 415 N/A N/A WEAR PARllCLES 0 Normal Rubblny Saeara Skdlny Cuklny Baahny NONFERRXJS 10 m

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NEW HILL,NC SHEARON HARRIS NUCLEAR POWER NORMAL SAMPLE ID:

SAMPLE DESC:

MANUFACTURER:

LUBRICANT:

RESERVOIR CAP:

TIMEON LUBE:

MACHINETIME:

SHNPP-A-EDG

'A'MERGENCYDIESEL GENERATOR ENTERPRISE MOBILGUARD 412 1,500.0 GAL f 5,677.5 LITERS J NOT PROVIDED-NOT PROVIDED SAMPLE DATE: 03/23/91 REC'D DATE: 04/19/91 REPORT DATE: 04/22/91 1st SAMPLE: 12/20/66 PREVSAMPLE: 03/11/91 fNJ NO. SAMPLES; 45 PROGRAM:

A1 Recommendatlon:

Sample at normal intervals; Discussion of Results:

Wear trends and other tests indicate that this unit is operating normally.

Wear Particle Concentration:

10 0

70 140 210 240 000 Ol/11/40 00/27/41 Analytical Results:

auaNTITaTIvE RESULTS:

WPC:

3.5 DL 2.7 DS:

.9 Mean:

10.8 Std Der.

3.8 AlannA 8.8 Alarm BH:

184 Alarm BL 3.5 Alarm MH:

NOT SET Alarm ML NOT SET Vlacoaftt/ (cst):

158 Water (%):

NEG Refrigerant NEG Viscosity <spec. 14.5cst@tcccI.

24 14 12

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70 140 210 240 050 01/11/40 07/27/41 Machine condition is such that no analytical test was required.

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EQUIPMENT CONDITION REPORT

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NEW HILL,NC SHEARON HARRIS NUCLEAR POWER NORMAL SAMPLE ID: SHNPP-AZDG SAMPLE DESC:

A'MERGENCYDIESEL GENERATOR MANUFACTURER'NTERPRISE LUBRICANT: MOBILGUARD 412 RESERVOIR CAP:

1,500.0 GAL [ 5,677.5 LITERS ]

TIMEON LUBE NOT PROVIDED MACHINETIME: NOT PROVIDED SAMPLE DATE: 04/14/91 REC'D DATE: 05/06/91 REPORT DATE'5/08/91 1st SAMPLE: 12/20/86 PREY SAMPLE: 03/23/91

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NO. SAMPLES: 46 PROGRAM'1 Recommendatlon:

Continue with normal operation. Salvlple at routine intervals.

OUANTtTATtVE RESULTS:

WPC:

18A OL 12.5 OS: 59 Mean:

10.8 Std 001'.8 Alarm A: 8$

Alarm BH:

18.3 Alarm BL 3.0 Alarm MH:

NOT SET Hamt ML NOT SET Vlaooalty (CSt):

14.8 Water (%):

NEG RefrtgeranC NEG VISCOSIty (spec. 1s.scst 101 100c)'ear Particle Concentration:

N rro 14 10 Spec.

10%

12 0

70 140 210 240 050 05/07/00 04/22/01 0

70 140 05/07/40 Analytical Results:

WEARPARnCtES 0 4

210 MAX 512E 10 RITMS 4

10 WEIRPARACLES 0 Normal RubSny Severe Skane Curine Sonny CCNTANINta 0 C14 NIA NIA 0 Copper 0 White 0 Babbitt JAM-149117 91454106 0000013941%1 001950 Discussion of Results:

Although the wear particle concentration has increased from 3.6 to 18.4, and is higher than the established baseline for this unit, analytical results indicate that this unit is operating normally. This sample only contains limited to moderate amounts of black oxides, red oxides, lubricant degradation, and dirt.

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L PMENT CONDITION REPORT,,:

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NEW HILL,NC SHEARON HARRIS NUCLEAR POWER NORMAL SAMPLE DATE: 10/07/91 REC'D DATE: 10/28/91 REPORT DATE: 10/30/91, 1st SAMPLE: 12/20/86 PREY SAMPLE: 09/01/91

[NJ NO. SAMPLES: 52 PROGRAM:

A1 SHNPP-A-EDG "A'MERGENCYDIESEL GENERATOR ENTERPRISE MOBILGUARD 412 1,500.0 GAL [5,677.5 UTERS j NOT PROVIDED NOT PROVIDED SAMPLE ID:

SAMPLE DESC:

MANUFACTURER:

LUBRICANT:

RESERVOIR CAP:

TIMEON LUBE:

MACHINETIME:

Recommendation:

Samp! e at normal intervals.

auANT)TATtvE AESULTS:

WPC:

13.1 DL 9.7 OS:

3.4 Mean:

11.4 Std Dev:

4.0 Alarm A:

23.0 Alarm BH:

19.6 Alarm Bl'.3 Alarm MH:

NOT SET Alarm ML NOT SET Viscosity (cSt):

15.0 Water (%):

NEG Refrigerant:

NEG Wear Particle Concentration:

VISCOSity <Sp 14.206t@1OOC)'.

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74 144 222 2se 070 10/12/00 10/1'7/01 Analytical Results: +

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74 140 222 290 070 10/12/00 10/17/01 Machine condition is such that no analytical test was required.

0000013941%1 001950

-173754 91-1 04523 Discussion of Results:

Wear trends and other tests indicate that this unit is operating normally.